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Critical Undersea Infrastructure White Paper: Cost Impact Survey

1. Introduction

This survey has been designed to gather evidence-based cost data from industry to support the ongoing policy development of the proposed subsea cable legislation and assess its potential impacts. This follows the publication of the ‘Critical Undersea Infrastructure Security and Resilience: Proposals for modernising the UK’s legislation’ White Paper and is intended to close evidence gaps identified in preliminary internal cost modelling. 

The survey covers three of the four proposed legislative strands set out in the White Paper. The Criminal Penalties regime (Chapter 3 of the White Paper) is excluded as penalties fall outside the scope of the Better Regulation Framework and are therefore not subject to independent Regulatory Policy Committee scrutiny. In addition, the Green Book (2026) treats penalties as an economic transfer rather than a resource cost to society, so they do not need to be included in this cost impact survey. The three strands covered in this survey are:

  • Strand A: Security and Resilience Duties (SRDs) – White Paper Chapter 4
  • Strand B: National Security Direction Power – White Paper Chapter 5
  • Strand C: Regulation of Sensing Technologies – White Paper Chapter 6

We are seeking your input on two categories of business burden:

  • Familiarisation costs: These are the one-off costs to your organisation of understanding the new obligations across the legislative package. This may include staff time to review the legislation and guidance, and any external professional input required to aid understanding (for example, legal advice). 
  • Compliance costs: The one-off implementation and annual ongoing costs of meeting the substantive requirements themselves. This may include, for example, implementing security measures, reporting obligations, and responding to government requests, directions or inspections.

 

1.1 Guidance on providing estimates

Please provide answers based on your organisation’s reasonable best estimates. In particular: 

  • Please provide incremental costs only, that is, costs over and above the activities, systems, staff time or external advice your organisation would already undertake without the proposed legislation.
  • Provide all estimates in Great British Pounds (£), using today’s (2026) pricing and excluding VAT.
  • Ranges (low/central/high) are welcome and preferred to single point estimates where material uncertainty is present.
  • Explain the key assumptions underpinning your estimates.
  • Where you are unable to provide a monetised estimate, qualitative information on cost drivers (for example “would require new dedicated compliance headcount”) is still useful information to provide.

1.2 Privacy notice

How the information you provide will be used 

Information provided in response to this questionnaire will be treated as OFFICIAL–SENSITIVE and will be handled in accordance with DCMS's data protection and information handling policies. Responses will be used solely for the purpose of impact assessment and policy development in relation to critical undersea infrastructure (CUI) legislation. Individual organisations' responses will not be attributed in any published material without prior consent. Aggregated and anonymised findings may be included in the final Impact Assessment relating to CUI legislation. 

Confidentiality and data protection

Information you provide in response to this consultation, including personal information, may be disclosed in accordance with UK legislation (the Freedom of Information Act 2000, the Data Protection Act 2018 and the Environmental Information Regulations 2004).

If you want the information that you provide to be treated as confidential please tell us, but be aware that we cannot guarantee confidentiality in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not be regarded by us as a confidentiality request.

We will process your personal data in accordance with all applicable data protection laws. See our privacy policy.

Quality assurance

This consultation has been carried out in accordance with the government’s consultation principles.

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